Code: Code of Ethics and Conduct CUMP-MAN-001 The Bank's ...

Code:

CUMP-MAN-001

Code of Ethics and Conduct

This Document shall be used as an instrument for executing each Audit.

Page 1 of 22 Date of Issue: December 2012

Version 12.0 Date of Last Update: May 2021

Objective

The Bank's Code of Ethics and Conduct has the following objectives: ▪ To foster and promote the values and behaviors that we seek to cultivate in the

Bank.

▪ Our directors, employees and stakeholders must always act ethically, regardless of their position, geographical location or level of responsibility.

▪ To ensure that its business activities are conducted in accordance with legal

standards applicable to the Bank.

▪ To maintain credibility, both institutional and individual, through high standards of ethical and professional behavior, in institutional operations and in generating business.

▪ Obtain results in an honest, fair, legal, and transparent manner.

▪ To strengthen the trust of our directors, employees, clients, suppliers and

investors, maintaining an environment of transparency and responsibility.

Scope

This Code is mandatory for all directors, employees, clients, suppliers, business partners, or interested parties, in order to ensure and strengthen the image of a reliable Bank due to the soundness of its principles and values aligned with those of the economic group that comprise it.

We must all be responsible for knowing and complying with this Code and for facilitating its implementation, including the communication of any known non-compliance therewith.

Documents

Related to

External

Standards

Central Bank of The Bahamas ▪ Guidelines for Corporate Governance related to the Bank’s processes,

structure, information, and management. Laws of the Republic of Panama

▪ Law 23 of April 27, 2015 Preventing Money Laundering, the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction

▪ Banking Law of the Republic of Panama ▪ Labor Code of the Republic of Panama

Superintendency of Banks of Panama

▪ Rule 2-2019, whereby Rule 10-2015 on preventing the misuse of banking and trust services is amended

▪ Rule 13-2018, whereby Rule 10-2015 is amended ▪ Rule 1-2017, whereby Rule 01-2015 to prevent the misuse of banking and

trust services is amended ▪ Rule 10-2015 to prevent the misuse of banking and trust services ▪ Rule 5 - 2011 Corporate Governance provisions

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Corporate

Documents

Intercorp Financial

Services

▪ Code of Ethics and Standards of Business Conduct ▪ Corporate Governance Manual ▪ Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT)

Manual

Other Related

Policies and

Processes

Policies:

▪ Corporate Governance ▪ Information Asset Management ▪ Management of Suppliers and Third Parties ▪ Operational Risk Management ▪ Facilities Security ▪ Anti-Corruption and Bribery ▪ Use of Confidential Information ▪ Use of Mobile Devices ▪ Use of email and internet ▪ Information Systems Security ▪ Password Management ▪ Human Development and Management

Processes:

▪ Ethical Whistleblower Channel Management ▪ Staff Selection ▪ Staff Onboarding and Hiring

Management of Prevention-AML/CFT Policies

▪ Client Onboarding ▪ Know Your Employee ▪ Know Your Financial Intermediary ▪ Ongoing Client Due Diligence ▪ Tax Compliance for U.S. Clients Abroad ▪ Client Compliance Risk Rating

Processes

▪ Client Investigation ▪ Monitoring of Alerts ▪ Unusual Transaction Analysis ▪ Updating of Employee Data ▪ Financial Intermediary Due Diligence ▪ Interm. Due Diligence to Bank and Account Opening ▪ Ongoing Client Due Diligence ▪ Enhanced Client Due Diligence

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Other Related

Policies and

Processes, cont.

Procedures ▪ Investigation ▪ Monitoring ▪ How to Check Background – Client Onboarding and High Risk Account ▪ How to Check Background - Transfers Sent to Third Parties ▪ How to Check Background – Onboarding Moderate or Low Risk Clients ▪ How to Check Background - Data update ▪ Preventive Freezing

Definitions

▪ Willful Blindness: Intentionally failing to see, hear or report inappropriate behavior

that makes us complicit in such behavior.

▪ Conflict of Interest: This is understood as a situation whereby a member of the Board of Directors, an employee, among others, who must make a decision or perform or omit an action due to their functions, has the option to choose between the interest of the Bank, client, user or supplier and their own interest, that of their family or of a third party in such a way that by choosing one of these last three, they would benefit financially or extra financially for themselves, their family or third party, ignoring their ethical, legal or contractual duty and obtaining an advantage that they would not otherwise receive.

▪ Appropriate Reporting Line: This refers to the upward reporting hierarchy.

▪ Stakeholders: This refers to clients, employees, directors, suppliers, business partners, and third parties with whom we have a direct or indirect relationship.

▪ Corporate Values: Value is understood as what makes a person act, guiding the person’s action; from an organizational point of view, values are what govern staff behavior, aligned with the achievement of the mission, vision and strategic objectives of the Bank.

Related Annexes

▪ Internal Labor Regulations

Vision

To ensure that our clients are the best advised in Latin America.

Mission

To advise our clients and their families in the management of their wealth throughout

their lives.

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Corporate Values

Guiding Our

Management

▪ Client Focused: We put our internal and external customers first, serving them with commitment and initiative.

▪ Excellence: We do things extraordinarily well by going beyond our limits, challenging ourselves to grow and learn.

▪ Integrity: We act with transparency, are guided by solid principles, and are fair and ethical.

▪ Teamwork: We give our best to achieve together the common goal that unites us.

▪ Sense of Humor: We enjoy what we do, transmit well-being to others, laughing at ourselves.

▪ Innovation: We explore, experiment and learn constantly to find new solutions that transform our company.

Bank Secrecy

▪ We will only disclose information about our clients or their operations with their

express consent, except when formally requested by a competent authority in

accordance with the law.

Our Principles

Loyalty

In fulfilling their duty of loyalty, each director, employee and stakeholder is obliged to protect the good name of the Bank. All persons connected with the Bank must comply with the laws of fidelity, honor and act legally and truthfully.

In accordance with this principle, they are obliged to devote their activity to the exclusive benefit of their stakeholders, in such a way that the benefit of their management is passed on in full to the latter, without prejudice to the compensation for the management carried out.

Transparency

The Bank must maintain clear conditions in its operations to enable appropriate decision-making, and it must keep its stakeholders informed of all circumstances relevant to their interests.

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Our Principles, cont. Equity

The Bank must establish a level playing field by granting equal conditions for its services and products without considering personal or third party benefits.

Diligence

To maintain the Bank's resources available to its clients and to perform in an effective, sufficient and satisfactory manner so that the objectives sought are met without deviating from legal mandates and ethical principles.

To this end, it must undertake:

✓ To act with rectitude. ✓ To provide services without expecting any remuneration other than that

agreed. ✓ To inform clients of the characteristics and conditions of the services

provided and the possibilities available to the institution to serve them.

Work Scheme and Responsibilities of the Ethics and Conduct Committee

Organization

▪ The Ethics and Conduct Committee shall be comprised of the following:

✓ General Manager ✓ International Division Manager ✓ Human Development Management Manager ✓ Compliance Manager ✓ Legal Manager

Administration of

the Code of Ethics

and Conduct

▪ The Ethics and Conduct Committee will be responsible for assessing and updating

this Code, reviewing and implementing the necessary mechanisms to disseminate and promote the highest standards of behavior in the Bank.

Reporting

Channels and

Whistleblower

Protection

▪ All our employees, directors, suppliers, clients or any other stakeholder may report anonymously if required through the channels implemented to report any inappropriate behavior. This can be done through the following means:

✓ Web channel https://canaleticointeligo.lineaseticas.com/ ✓ Telephone exchange: 0080-0052-0569

▪ To ensure objectivity and confidentiality of complaints, the Bank has commissioned

a specialized company to receive and register them, which will be responsible for referring the cases to the person in charge of managing the ethical channel and activate the protocol for scaling up complaints in such cases where necessary.

https://canaleticointeligo.lineaseticas.com/

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Work Scheme and Responsibilities of the Ethics and Conduct Committee

Functions of the

Ethics and

Conduct

Committee

▪ To decide on actions to be taken and recommend corrective actions on cases of

non-compliance with the ethics policy and guidelines that are submitted thereto.

▪ Any other situation where there is doubt due to not being covered by this Code, should be consulted with the Ethics and Conduct Committee for due verification.

Non-Compliance

Report

▪ It is the responsibility of each of the Bank's members to notify when they become

aware of any non-compliance with the Code of Ethics, related to: ✓ Conflict of interest ✓ Suspicious activity, ✓ Insider trading, ✓ Fraud or attempted fraud, ✓ Accounting records that do not comply with international financial reporting

standards ✓ Any mysterious disappearance of funds or securities. ✓ Anti-Corruption and Bribery Policy

You may do so by contacting the person(s) appointed by the Bank for this purpose, through the ethical reporting channel established therefor. ▪ The Human Development and Management Manager will keep a record and

custody of infringements, including dates of the events and actions taken, which must be considered confidential. Except as required by law or this Code, such matters will not be disclosed to anyone outside the Ethics and Conduct Committee and the Board of Directors of the Bank.

▪ The Audit Committee and the Board of Directors shall be responsible, according to the reports submitted by the Human Development and Management Area, for monitoring and ensuring compliance with the stipulations of the Code of Ethics and Conduct.

▪ Any situation not covered in this section of penalties will be managed in accordance

with local labor regulations.

Commitment to Our Directors and Employees

Personal Finance Management

▪ We must manage our personal finances properly to avoid situations that affect the

Bank's image. ▪ We must refrain from being guarantors for any type of commercial transaction

carried out by another employee or a client.

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Diversity, Equal Opportunities and Respect

▪ We foster a motivating and creative environment, where promotions, career paths

and salaries are available on equal terms to all, according to the knowledge, attitudes, skills, and merits required for the different jobs.

▪ We cultivate an inclusive and collaborative culture to retain our talents and maximize their potential.

▪ We value and promote cultural diversity and gender equality within our work teams, maintaining an environment of respect and valuing individual differences to take advantage of the talent of each employee, free from harassment.

▪ We encourage honest communications between Bank members.

▪ We consult when necessary and respect the opinions of those who differ from us.

▪ We respect the work environment and build trusting relationships with our directors, maintaining a safe and inclusive environment with respectful, fair, dignified, and courteous relationships with each other.

What is forbidden?

▪ Aggressive verbal or physical behaviors aimed at intimidating, hurting, scaring,

threatening, or intentionally excluding a person or stakeholders in particular.

▪ Hostile or offensive treatment of a person in the workplace, by any means.

▪ Sexual advances, sexually offensive acts and comments, conversations,

gestures, sexist, indecent or obscene comments.

▪ Discrimination on the basis of race, ancestry, gender, age, religion, nationality,

educational background, political affiliation, physical disability, marital status,

sexual orientation, or any other characteristic. The above characteristics will

also not influence job opportunities, professional and personal development of

the employees.

▪ Allow or refrain from reporting any conduct that violates the integrity of the

individual.

Sexual or

Psychological

Harassment

▪ We practice zero tolerance for sexual or psychological harassment or acts of

intimidation of any kind. ▪ We reject any form of activity that is considered forced labor under the laws or

international conventions. ▪ We must show consideration and respect for others and abandon any attitude

deemed offensive by another person at the first sign thereof.

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Training

▪ All directors and employees are required to attend any training that the Bank deems necessary.

Proper Use and

Care of the Bank’s

Property and

Assets

▪ We must protect the Bank’s assets and property. Such assets and property include

not only those assigned to the performance of individual and group work, but also those that the Bank makes available to all directors, employees or stakeholders, such as furniture and furnishings, protecting them against risks of loss, damage or misappropriation.

▪ Refrain from using:

✓ Equipment or facilities assigned for the performance of their duties for particular purposes.

✓ Time of working day for personal matters. ✓ Technology, methods and processes developed for the use of the Bank for

particular purposes or benefit of third parties.

Language and

Tone of Voice to

be Used

▪ When interacting with clients, co-workers, directors, suppliers, third parties or any

other person, we must use appropriate language and tone of voice, where courtesy and respect prevail.

Social

Responsibility

▪ We comply with legal standards and the implementation of existing or

recommended international best practices regarding social responsibility.

Safe and Healthy

Environment

▪ We promote a culture of safety based on prevention, maintaining a safe and healthy work environment for the directors, employees, and visitors, complying at all times with the safety provisions established by the Bank.

▪ We take action and report risks or accidents promptly to implement the necessary measures.

▪ perform our duties in an environment free of alcohol or drug consumption.

What is forbidden?

▪ The deliberate, negligent or careless breach of the safety and health guidelines

issued by the Bank.

▪ Any behavior that puts at risk the safety and health of directors, employees,

and third parties on the premises.

▪ Using, working or entering the Bank under the influence of toxic substances,

alcoholic beverages or drugs during the performance of our duties or outside

of our working hours as long as we are on the premises of the Bank.

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Safe and Healthy

Environment,

cont.

What is forbidden?

▪ Smoking inside the Bank’s facilities.

▪ Allow or refrain from reporting conduct that threatens the safe and healthy environment at the Bank.

Handling

Interpersonal

Relationships at

Work

▪ Every person in a supervisory position should model the behaviors they expect from

their staff and strengthen mutual feedback with their team with respect and empathy.

▪ The high level of professionalism in the interpersonal management of the Bank's

directors and staff will be characterized mainly by:

✓ Quality of results obtained in teamwork.

✓ Satisfaction of the Bank's clients.

✓ Productivity and results-oriented work environment.

✓ Respect for individual differences and opinions contrary to one's own.

✓ Fair, objective and equitable treatment in the working relationship.

✓ Facility for organizational and human development and growth.

✓ Rejection of harmful behaviors, such as using degrading words to describe a person, talking behind others' backs, tolerating alcohol and drug addiction.

✓ To carry out the tasks assigned by superiors and comply with the instructions given by them and the relevant hierarchical bodies, adopt open communication for advice and help, as well as an attitude of transparency, in dealing with superiors and other co-workers.

✓ Compliance with institutional policies, standards and procedures.

▪ Attitudes such as withholding information from superiors or co-workers that could

affect the performance of work, especially for the purpose of personal gain, or providing false, inaccurate or distorted data, refusing to collaborate with co-workers or practicing any form of obstruction, are contrary to the kind of loyalty that can be expected from all directors and employees of the Bank.

▪ We must keep co-workers who have a relationship with the Bank informed of the work in progress and allow them to contribute.

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Employment

Outside the Bank

▪ Hold positions as a director, partner, consultant or any paid employment with institutions or corporations where there is a business relationship or are considered as competitors. In the event of this situation, written notification to the Bank and its approval is required.

▪ An employee may accept part-time employment outside the Bank in coordination with their immediate manager, as long as those obligations do not interfere with the employee's work, that is, another Bank or Financial Institution.

▪ Management must consider aspects, such as: ✓ Avoiding conflicts of interest. ✓ That this work does not influence the physical or mental rest that the employee

needs to work satisfactorily in the Bank. ✓ If the employee suffers an accident at work (occupational hazards) in the other

job, it would not be the Bank's responsibility to acknowledge such disability.

▪ In case of doubt, managers are advised to consult the General Manager if such a situation arises.

Relationship,

Consanguinity

and Affinity

▪ The Bank will avoid hiring family members of directors, employees or active stakeholders up to the third degree of consanguinity and affinity to maintain the Bank's objectivity in its decisions.

▪ Any relationship or affinity that may arise in the work environment must be notified

to the Department of Human Development and Management at the time it becomes known, for the corresponding evaluation with the General Manager. Annex No.1 shows the degrees of Consanguinity and Affinity.

Private

Investments

▪ Although the Bank does not intend to limit the private investment activities of its

directors and employees, nor those of their respective associates, it considers that they should avoid participating in investment transactions that could generate a conflict of interest between the directors, the employee, the Bank or a client.

▪ The following specific situations should be avoided when making an investment decision: ✓ Making investments in securities in companies owned by a supplier, borrower

or competitor, as these investments could be considered to affect the judgment of the employee when acting on behalf of the Bank.

✓ Making investments in a company where there is a possibility of using private information related to that company.

✓ Making investments for an employee or in the account of an employee or in that of their immediate family members, from a client of the Bank or of any company within the Group.

✓ Making investments sponsored by a client in circumstances that may give rise to conflicts of interest or the appearance of such conflicts.

✓ Carrying out activities in parallel investments or in anticipation of an investment by the Bank of any of the companies in the Group.

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Commitment to Our Shareholders and Investors

Relationship with

Shareholders

▪ Relations with our shareholders will be based on transparent, objective and timely

communications, which will allow them to monitor the progress and performance of the Bank at all times according to the parameters established in the Corporate Governance Manual.

▪ Information that has not been publicly disclosed must be kept confidential in order to protect the interests of the Bank's shareholders.

Integrity of

Financial Reports

▪ We ensure the timely, complete, correct, and accurate recording of transactions

and operations for the purpose of reporting appropriate information for decision making.

▪ We maintain accurate, timely, clear, and complete financial data, records, agreements, transactions, operations, and reports.

▪ We record information in compliance with applicable accounting controls, regulations, practices and other standards

▪ We disclose complete, fair, timely, and clear information in our public communications, regulatory disclosures and reports submitted to shareholders, investors and regulators

What is forbidden?

▪ Falsifying or manipulating in any way financial reports.

▪ Voluntarily providing or recording false or misleading accounting or auditing

data.

▪ Allowing or refraining from reporting, conduct that undermines the integrity and

transparency of information.

Protection of

Classified

Information and

Intellectual

Property

▪ We protect the confidential information of our Bank, directors, employees, clients, suppliers, and other stakeholders.

▪ We use insider information responsibly, solely for corporate purposes and prevent

it from being used for other purposes. ▪ We protect our intellectual property and our information systems, encouraging the

appropriate use of the information we reproduce or distribute by any physical or electronic means.

▪ We reserve the right to monitor and inspect the manner in which the directors and

employees use our assets, which may include e-mails, data and files maintained on the Bank's equipment or network; always within the framework of applicable legislation.

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Protection of

Classified

Information and

Intellectual

Property, cont.

What is forbidden?

▪ Using, appropriating or improperly disclosing confidential, restricted or

privileged information without authorization, including personal data of clients,

directors and employees, as well as information protected by specific laws and

regulations applicable in the financial sector, stock market or internal policies.

▪ Disclose business strategies, campaign information, market strategies,

strategic plans, and anything related to data that may place the

competitiveness of the Bank at risk.

▪ Improperly using accesses, keys or passwords that have been provided

personally for performing functions.

▪ The deliberate, negligent or careless breach of guidelines on information

security, protection of personal data and privileged information policies issued

in the Bank.

▪ Concealing or refraining from reporting any misuse or violation of classified

information and intellectual property

Prevention of

Internal and

External Fraud

▪ We reject any form of fraud by acting with integrity and avoid covering up, altering

or omitting information for private gain or that of third parties.

▪ We take care of the Bank's resources by using them responsibly and honestly to

do our job.

What is forbidden?

▪ Any act that involves the use of deception to obtain an unfair or illegal

advantage or any personal benefit.

▪ Theft, misappropriation of money or property of the Bank or of clients, directors,

employees, suppliers, and other persons.

▪ Misuse of the resources or assets of the Bank allocated for the work.

▪ Inciting directors, employees, suppliers, or clients to participate in dishonest or

fraudulent acts.

▪ Concealing or refraining from disclosing dishonest or fraudulent acts through

appropriate channels.

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Conflict of Interest

▪ We avoid situations in which our relationships or personal interests may unduly influence the performance of our responsibilities or work decisions.

▪ We consult and seek approval of the appropriate reporting lines in case we identify any situation that may affect or have the appearance of affecting our ability to make the best decisions for the benefit of the Bank.

▪ We reject conduct in which gifts, hospitality and entertainment influence objective decision making.

▪ We report any irregular conflict of interest behavior that undermines the interests and reputation of the Bank, as set forth in our selection and hiring guidelines.

What is forbidden?

▪ Conducting personal business within and outside the Bank that may hinder the

performance of duties or objective decision making.

▪ Handling transactions or intervening in processes of recruitment or selection

involving family members or friends.

▪ Maintaining sentimental relationships with employees, directors or suppliers

with whom there is a direct relationship of control, subordination or reporting,

as well as in other cases where this may hamper objective decision making.

▪ Making or becoming aware of any conflict of interest and not reporting it.

▪ Being a shareholder, director or representative of any supplier of the Bank,

without having the respective authorization when your functions are related to

the service provided by such supplier.

Protection of

Reputation

▪ We represent the Bank in a responsible manner, including in environments not

related to our work, such as family and social settings, within the framework of upright behavior and within the law.

▪ We protect and strengthen the image, reputation, assets, and culture of integrity of the Bank and that stakeholders comply with our ethical standards.

▪ We carry out off-site activities in a responsible manner, always taking care of our reputation, including the responsible use of our personal social networks.

What is forbidden?

▪ Any behavior or statement disseminated through physical or digital mass

media, in social networks, that undermines the image or reputation of the Bank,

even if it has been made in a personal, social or family sphere.

▪ Engaging the image of the Bank in personal activities of a political, sporting or

social nature.

▪ Concealing or refraining from reporting conduct that may affect our reputation

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Commitment to Authorities

Relationship with

the Public Sector,

Compliance with

Laws and

Regulations

▪ The courtesy of the Bank and its representatives to members of regulatory bodies should be an institutional feature. These relations should not be used for personal gain or benefit of the Bank as a work team member of the Bank. We must at all times observe high civic standards and respect the laws.

▪ The Bank is subject to a number of laws and regulations governing its operations

in different countries. We have therefore adopted a culture of continuous updating to meet legal standards and reflect the reality of operations in accordance with applicable accounting principles.

▪ We must know and understand the legal aspects applicable to the performance of

the assigned tasks, to the activity of the department and the Bank as a whole, in order to avoid any legal problems to the Bank.

▪ We comply with national and international regulations issued in the jurisdictions

applicable to the Bank. ▪ We ensure compliance with the Bank's internal policies and guidelines to conduct

business with integrity.

What is forbidden?

▪ The deliberate, negligent or careless breach of compliance policies and

guidelines, as well as any breach of national and international regulations

applicable to the Bank.

▪ Omitting or refraining from immediately reporting any indication or incident

involving behavior that goes against the guidelines of integrity and compliance

of the Bank.

Anti-Money

Laundering and

Countering the

Financing of

Terrorism

▪ We implement robust processes and are continuously training to prevent any activity related to money laundering and financing of terrorism.

▪ We promote a culture of compliance based on integrity and transparency in the

execution of the internal controls established through policies, processes and procedures related to the anti-money laundering and countering the financing of terrorism system.

▪ We undertake to comply with and put into practice the behavioral guidelines

established for the purpose of ensuring the duty of undisclosed confidentiality of information related to the anti-money laundering and countering the financing of terrorism system, which includes the following

✓ Cooperating fully with local judicial and regulatory authorities and operating in

full compliance with applicable laws and regulations. ✓ Know Our Client. ✓ Reporting suspicious transactions. ✓ Developing an anti-money laundering environment through procedures,

training and awareness.

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Prevention of

Corruption

▪ We act in a responsible manner, complying with anti-corruption laws and the

Bank’s policies and guidelines aimed at preventing any act of corruption by public and private officials.

▪ We implement processes and receive continuous training to prevent acts of corruption.

What is forbidden?

▪ Offering, promising, delivering, soliciting or accepting any kind of reward,

benefit or incentive (gift, care or any other effect of value), as well as any

contribution, donation or sponsorship in a personal capacity, of the Bank, for a

public or private official to act or refrain from acting in an official capacity, or to

improperly influence a business decision.

▪ Negotiating with individuals from private or public entities to obtain an undue

advantage for the Bank.

▪ The deliberate, negligent or careless breach of policies and guidelines issued

by the Bank for the prevention of acts of corruption.

▪ Concealing any indication of activities of bribery or corruption involving a client,

employee or supplier.

Relationship with

Public Officials

▪ We establish transparent and ethical relations with authorities and public officials. Any meeting on behalf of the Bank must be held with the prior authorization of the appropriate reporting lines.

▪ We respond to regulators and their agents in an honest and transparent manner,

fulfilling assumed commitments, providing accurate, appropriate, and timely information for proper supervision.

▪ We carry out our business activities with integrity, impartiality and without any

political influence. ▪ We do not make donations or political contributions to candidates or parties with

the Bank’s resources. If an employee makes political donations or contributions, in no case shall they be made using the name of Inteligo Bank.

What is forbidden?

▪ Making an offer to a public sector representative with the purpose of obtaining

favorable treatment.

▪ Offering or making political donations or contributions on behalf of the Bank to

positions or events held by political candidates, parties or organizations.

▪ Allowing or failing to report any misconduct with public officials.

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Participation in

Political Activities

▪ The Bank’s directors and employees are personally free to participate in political

activities in the community, in their free time. This participation is voluntary and any opinions expressed are in their own name and not in representation of the Bank.

▪ Refraining from using the Bank's or the Group's trademark in any meeting, press release, news item or article related to political activities.

▪ It is forbidden to carry out proselytizing, political or religious activities on the Bank's facilities or in meetings.

▪ No individual political effort will be compensated or reimbursed by the Bank.

Participation in

Non-Profit

Organizations

▪ Some directors and employees generously contribute their time to a variety of

organizations such as civic, religious, charitable, cultural, and educational organizations. The Bank supports these efforts, however, care must be taken with the following: ✓ Serving in one of these non-profit entities is done in a personal capacity and

should not imply or mention that the Bank contributes to such organization. ✓ The use of the Bank's facilities, time and other resources for the benefit of

these non-profit entities should be consulted with and duly approved by the General Manager.

Commitment to Our Competitors, Clients, Suppliers, and Business Partners

Relationship with

Our Competitors

▪ We refrain from making comments that may affect the image of competitors, referring to competitors or their brands in a negative or derogatory manner or continue to spread rumors about them. Treating other financial institutions with the same treatment that the Bank expects to be treated.

▪ We conduct our business based on free and fair competition, promoting innovation, continuously improving our products and services, and generating profits in the marketplace.

▪ We develop our business policies, prices and commercial aspects independently from competitors.

▪ We compete in a fair and honest manner, based on our ethical principles and in full compliance with the legal standards that regulate the markets.

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Relationship with

Our Competitors,

Cont.

▪ We avoid carrying out acts that are intended to hinder, restrict or distort

competition.

What is forbidden?

▪ Taking undue advantage of the position of market leader or making

agreements with other companies to manipulate marketing conditions, prices

or bidding processes.

▪ Boycotting our competitors by any means, or misuse the reputation, image or

intellectual property of other companies.

▪ Conducting, allowing or omitting to report any anti-competitive conduct.

Relationship with

Our Clients

▪ Our commitment to our clients’ satisfaction will be demonstrated by respect and

the search of solutions to their needs, maintaining a balance with the Bank’s business and profitability objectives.

▪ We treat our clients with courtesy, respect and dignity, providing them with clear,

concise and transparent information to make informed decisions. At no time should we give preferential treatment to our clients because of their own interests or personal affinity.

▪ Those directors and employees entitled to request information from the clients or

future clients of the Bank will request the necessary information for their proper identification, as well as information about their financial situation, business plans or future objectives, when these are relevant to the services offered or to be offered to them, always based on their risk profile.

▪ Non-public information obtained from clients or future clients, in accordance with

the above, will be treated as confidential information.

▪ We honor our commitments and are transparent in our relationships with clients. ▪ We are committed to maintaining the trust and loyalty of our clients.

What is forbidden?

▪ Resorting to ambiguous or misleading terms or explanations, as well as

withholding relevant information so that clients can make informed decisions.

▪ Making, allowing or failing to report any misconduct that is against the interests

of our clients.

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Relationship with

Our Suppliers,

Business partners

and Third Parties

▪ The Bank refrains from hiring suppliers who: ✓ Are linked to an investigation into money laundering, drug trafficking or

corruption, or are convicted of participating in illegal activities or in violation of the laws that apply to them.

✓ Have family relationships with directors, employees of the Bank or legal entities whose controlling person is one of such persons, except in cases where the Board of Directors approves their hiring.

▪ We value our suppliers, business partners and third parties, as strategic business

allies and recognize their importance in achieving our objectives. Therefore, we seek to ensure that they conduct their business ethically.

▪ We are transparent and fair in our processes of negotiation and selection of suppliers taking into account their background, quality of service, reputation and other merits, as well as rejecting any practice that consists in offering commissions, bonuses or other improper remuneration in order to obtain an illegitimate benefit..

What is forbidden?

▪ Unduly favoring a supplier in a selection or award process.

▪ Soliciting or receiving gifts, entertainment or bribes from a supplier.

▪ Making, allowing or failing to report any misconduct that reflects a lack of

integrity in the relationship with our suppliers, business partners and third

parties.

Ethical Guidelines

Offenses and

Penalties

All directors, employees and stakeholders are responsible for knowing and understanding the conditions set forth in the Code of Ethics and Conduct.

Any failure to comply with the provisions of this Code will result in disciplinary penalties including observations, penalties and dismissal.

Minor offenses are those that do not comply with the instructions given in the Code of Ethics and Conduct, standards, policies and guidelines approved by the Bank.

The applicable penalty will be a verbal warning under the responsibility of the Area Manager or the applicable local labor regulations.

Less serious offenses correspond to reiterative non-compliance with the instructions given in the Code of Ethics and Conduct, standards, policies, and guidelines approved by the Bank, during the term of one year from the offense.

Code:

CUMP-MAN-001





Ethical Guidelines

Offenses and

Penalties, cont.

The applicable penalty would be a written warning under the responsibility of the Area Manager or the applicable local labor regulations.

Serious offenses are those that are proven to have been committed for money laundering or terrorist financing fraud, in violation of our Code of Ethics and Conduct, standards, policies, and guidelines approved by the Bank.

The applicable penalty will be under the responsibility of the General Manager of the Bank and may be: suspension of work, dismissal or legal proceedings in accordance with local labor regulations.

Note: Any situation not covered in this section of penalties will be handled in accordance with local labor regulations.

The penalty to be applied will depend on each case and will always be consulted with the Compliance and Legal Areas. These can range from a severe reprimand to termination. Likewise, civil and criminal actions could be taken and even the possibility of not receiving variable income (performance bonuses or others) if applicable.

The following are considered very serious offenses:

✓ Failure to comply with the anti-corruption laws and guidelines described in the Anti-Corruption Program may result in significant civil and criminal penalties for both the Bank and Employees, Directors, Stakeholders, or Third Parties involved (including substantial fines and imprisonment), and in significant reputational damage.

✓ Directors, Employees or Third Parties who become aware of potential non-compliance with the Anti-Corruption Program failing to report it through the Bank's formal communication channels. This act is not only considered a very serious offence, but will also be subject to disciplinary action.

Any Director, Employee or Third Party shall be subject to disciplinary action if they engage in the following:

▪ Mislead or obstruct investigations into potential breaches of the Anti-Corruption Program.

▪ Retaliation in any form against those who provide information on acts that

infringe this Code of Ethics and Conduct.

▪ Willful blindness, i.e., becoming aware of potential breaches of this Code of Ethics and Conduct and not reporting them through the available ethical channel.

Code:

CUMP-MAN-001





What Prevails

between this

Code, Internal

Policies and

Applicable Laws?

▪ The Code of Ethics and Conduct forms part of the Bank's regulatory framework,

together with the Internal Labor Regulations, the Policy, Standards and Procedures Manuals and other Operating Instructions.

▪ In case of doubt regarding the interpretation of the content of this Code or its respective application, or particularly regarding conflicts of interest, the Ethics and Conduct Committee should be consulted.

▪ In the event of a conflict between the provisions of this Code and the applicable law, the applicable law shall prevail.

Code:

CUMP-MAN-001





Annex 1

Certificate of Understanding of the





I certify that I have read Inteligo Bank's Code of Ethics and Conduct and understand the standards of behavior that

are expected while our relationship is maintained, as comprised of the Standards of Conduct, Conflict of Interest

Policy, Confidentiality, Conduct Guidelines, and Price Manipulation.

It is understood that this Code provides for appropriate penalties in cases of non-compliance with established

regulations.

I am also aware that there is an Ethical Channel managed by an independent company that handles complaints

and investigations in accordance with the scaling-up protocol.

I accept and understand all the guidelines set forth in Inteligo Bank's Code of Ethics and Conduct and undertake to comply with them.

NAME

PERSONAL ID CARD

SIGNATURE

DATE

Note: The Code of Ethics and Conduct applies to all directors, employees, clients, suppliers, business partners, and stakeholders.